For new 404(c) plan, how do we get info to participants

[Guest neoplanner]

How exactly do large publicly traded companies get required 404© information to participants.... prospectus, confidentiality information, etc. Is there any guidance out there for the practical operational things a new plan needs to know? You know.... Running a 404© for Dummies!!

[Ron Snyder]

Put it in the SPD.

[JanetM]

We carpet bomb them with large envelopes full of tissue paper booklets, SPDs, and SMMs via the US mail. Kind of like AOL used to do with software CDs.

Adds expense, but is easiest way to get information to 20,000 participants in just about every state. HR at large plants frowned when we suggested shipped the stuff to the locations and having them hand it out.

[KJohnson]

Prospectus delivery is by far the biggest problem since it is "dynamic" and can't be accomplished through annual enorllment meetings or the like. The SEC only requires delivery to the Plan and not the individual participant. Making a prospectus "available" on line or otherwise is not sufficient to constitute delivery. I would think that this would be an issue in any large Plan RFP and you would not go to a provider who could not promise to deliver a prospectus directly to a participant immediately after the particpant firsts invests in any mutual fund.

[Guest westford111]

"Carpet bombing" and SPDs are standard ways of providing 404© protection, but there are other supplemental issues to be mindful of: 1. find a provider that will assume contractual 404© liability; if you can't, or even if you can, 2. make 404© educational materials part of the required training package for new employees.